TURMEL: Crown's Supreme Court "All Sections" Memorandum

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Date: 15 Dec 2004 04:21:05 GMT

Court File No.: 30571
               IN THE SUPREME COURT OF CANADA
      (ON APPEAL FROM THE COURT OF APPEAL FOR ONTARIO)

BETWEEN:
                       JOHN C. TURMEL
                                       Applicant (Appellant)
                           -and-
                   HER MAJESTY THE QUEEN
                                     Respondent (Respondent)

RESPONSE TO THE APPLICATION FOR LEAVE TO APPEAL RESPONDENT, HER
MAJESTY THE QUEEN
(Rules 6,27 and 49 of the Rules of the Supreme Court of Canada)

MEMORANDUM OF ARGUMENT IN RESPONSE TO THE APPLICATION FOR
LEAVE TO APPEAL

PART I - STATEMENT OF FACTS

A. OVERVIEW

1. The Applicant was charged with possession of marihuana for the
purpose of trafficking, contrary to section 5(2) of the
Controlled Drugs and Substances Act1 (CDSA). Before a trial date
was even scheduled, the Applicant brought an interlocutory
application in the Superior Court of Ontario, seeking an order
"quashing the count under s. 5 [of the CDSA] and declaring that
marijuana is no longer on Schedule II of the Controlled Drugs and
Substances Act".2 The application was dismissed.

2. The Applicant then appealed to the Court of Appeal for
Ontario, and argued that, as a result of that court's decision in
R. v. Parker, marihuana had ceased to be listed as a controlled
substance on Schedule II of the CDSA and, therefore, the offence
of possession of marihuana for the purposes of trafficking in s.
5 (2) of the CDSA was no longer in force at the time he was
charged

3. The Court of Appeal, on October 7,2003, dismissed the
Applicant's appeal. Although the Court of Appeal noted that there
were questions as to whether the motion was properly brought, and
whether the Superior Court even had jurisdiction to hear it, the
Court addressed the Applicant's argument and held that the
offence of possession of marihuana for the purpose of trafficking
remained in effect.3

4. The Applicant now, one year after the decision of the Court of
Appeal, seeks leave to appeal to this Honourable Court to seek a
declaration that the word "marijuana" was deleted from Schedule
II for all offences set out in the CDSA, in reliance on the Court
of Appeal's decision in R. v. Parker? As well, he raises a legal
issue not raised in the courts below. "When legislation is struck
down, is it reasonable for the government not to re-print the
legislation to effect the repeal and to count on the courts to
remember where the written word no longer applies?'0

5. The Applicant is eleven months late in seeking leave to appeal
and well out of time to bring this Application. The Applicant has
not brought a motion to seek an extension of time to file his
leave application. Instead, he seeks an order abridging time for
service, filing, or the hearing of the application.6 Assuming
that we can treat the Applicant's application for leave to appeal
as an application to extend time, he has failed to file any
affidavit evidence to justify such an extraordinary delay, as
required by the rules. Although self-represented, the Applicant
is a very experienced litigant.

6. Even if an extension of time were to be granted, leave to
appeal should be denied. No error of law arises on a question of
any national or public importance. The appeal is also without
merit. As the Court of Appeal properly held, the declaration of
invalidity made by that court in R. v. Parker was only applicable
to the offence of simple possession of marihuana in section 4 of
the CDSA, and did not extend to any other offence provision in
the CDSA. Moreover, the Applicant did not have a right of appeal
to the Court of Appeal in any event, and this Honourable Court
should not permit the Applicant to continue to use interlocutory
proceedings to delay his criminal trial on the merits. Finally,
the Applicant now seeks leave to appeal to this Honourable Court
to raise a legal issue that was never argued in the courts below.

B. HISTORY OF LEGAL PROCEEDINGS

7. On July 31, 2000, the Ontario Court of Appeal, in R. v.
Parker,1 held that the criminal prohibition against the
possession of marihuana in section 4 of the CDSA was of no force
or effect in the absence of a constitutionally acceptable medical
exemption from that prohibition. The Court, however, suspended
its declaration of invalidity for a period of one year to provide
the Government with sufficient time to address the constitutional
deficiency.8

8. In July 2001, prior to the expiry of the one year suspension
period granted by the Court in Parker, the Government promulgated
the Marihuana Medical Access Regulations? which permitted, in
certain circumstances, the possession and production of marihuana
by individuals for medical purposes.

(1) The decision of the Superior Court of Justice (Aitken, J.)

9. On or about May 14, 2003, the Applicant was charged under the
CDSA with the offence of possession of marihuana for the purposes
of trafficking, in an amount not exceeding 3 kilograms, an
offence within the absolute jurisdiction of a provincial court
judge pursuant to s. 553 of the Criminal Code.11

10. On or about May 20, 2003, the Applicant brought a motion to
quash the Information in the Ontario Superior Court of Justice.
His Notice of Motion requested the following relief:
"1. an Order pursuant to Rule 601 (1) to quash the
indictment for the defect apparent on the face thereof
that discloses no offence known to law;
2. an Order of mandamus that the Attorney General cease
all further prosecution of charges no longer known to
law and commence expunging all convictions under said
statute which is unknown to law;
3. an Order of prohibition that the Attorney General
from [sic] laying all further new charges under said
statute no longer known to law;
4.an Order striking condition (3) of the release in the
undertaking given to a Justice of the Peace dated May
15 2003."12

11. The Applicant argued that the Court of Appeal for Ontario, in
R. v. Parker,13 had "invalidated the prohibition on marihuana" in
the CDSA and the court's Order had the effect of "deleting"
marihuana as a controlled substance from Schedule II of the
CDSA.14

12. On May 26, 2003, Aitken, J. dismissed the Applicant's
application to quash the Information. Aitken, J. found that,

"The Applicant's motion is dismissed. The Applicant has
been charged under s. 5 (2) of the CDSA. The
declaration of the Court of Appeal in the case of R. v.
Parker (2000), 49 O.K. (3d) 481 relates to s. 4 (1) of
the CDSA, namely simple possession of marijuana. It
does not apply to s. 5 (2), possession for the purpose
of trafficking."15

(2) The decision of the Court of Appeal for Ontario (Doherty,
Goudge, and Simmons, JJA)

13. The Applicant appealed the decision of Aitken, J., repeating
his argument that marihuana was no longer listed on Schedule II
of the CDSA.

14. The Court of Appeal for Ontario dismissed the Applicant's
appeal. The Court found that marihuana continued to be a
controlled substance listed on Schedule II of the CDSA, and thus
the offence of possession of marihuana for the purposes of
trafficking continued to exist on May 26, 2003. The Court stated:

[4] While there are questions about whether this motion
was properly brought, and whether the Superior Court
had jurisdiction to hear it, we prefer to deal with
this appeal by addressing directly the argument made by
Mr. Turmel.
[5] It is based on a fundamental misconception. A
declaration does not delete a provision from a statute.
Pursuant to s. 52(1) of the Constitution Act, 1982 its
effect is to render the provision of no force or effect
to the extent of its inconsistency with the provisions
of the Constitution.
[6] The declaration of invalidity made by this court in
Parker, supra, does not delete marihuana from Schedule
II of the CDSA. It simply declares that the reference
to marihuana in Schedule II is of no force or effect
for the purposes of the possession charge in s. 4 of
the CDSA. The declaration does not extend to any other
section of the CDSA. In particular, it does not
diminish the effect of the listing of marihuana in
Schedule II for the purposes of s. 5(2) of the CDSA. As
a result, the charge of possession of marihuana for the
purposes of trafficking existed on May 26, 2003.
[7] Thus Aitken J. was correct to dismiss the
appellant's argument and we would dismiss his appeal.

C. THE PRESENT LEAVE APPLICATION

15. The time period within which to seek leave to appeal from
this decision expired on December 8, 2003.

16. On October 7, 2004, one year after the Court of Appeal
released its decision, the Applicant served and filed the within
application for leave to appeal to this Honourable Court.

PART II - QUESTIONS IN ISSUE

17. The Respondent submits that the simple issue that arises on
this Application for Leave to Appeal is whether a question of law
of national or public importance arises in the circumstances of
the case.

18. There is no question of law of national or public importance
that arises on the facts of this case. The decision of the Court
of Appeal for Ontario was manifestly correct, and there is no
right of appeal from an interlocutory proceeding in criminal
matters in any event.

PART III - ARGUMENT

A. THERE IS NO QUESTION OF NATIONAL OR PUBLIC IMPORTANCE
 
19. The leave application, which is now brought one year after
the decision of the appellate court below, does not give rise to
a question of national or public importance.

20. The Applicant has raised one legal issue in his Application
for Leave to Appeal: Whether the government is required to re-
enact legislation if it wishes to restore legislation that has
been "repealed".18 The Applicant argues that when the Ontario
Court of Appeal in Parker declared to be invalid the reference to
marihuana in Schedule II for the purposes of the offence of
possession of marihuana in section 4 of the CDSA, that Order
effectively deleted marihuana from Schedule II to the CDSA,
thereby removing marihuana from the list of controlled substances
under the CDSA.19 The Applicant argues that as a result the
offence of trafficking in marihuana had been "repealed".

21. The Applicant's argument, however, is grounded on a
fundamental misunderstanding of the effect of the Court of
Appeal's order in Parker^ In Parker, the Court of Appeal
determined that the prohibition against simple possession of
marihuana in the CDSA was overly broad, as the legislative scheme
failed to provide an exemption for medical use. The
constitutional validity of the offence of possession of marihuana
for the purpose of trafficking, in s. 5(2) of the CDSA, was not
before the Court of Appeal in Parker.21

22. The Court of Appeal found that the Applicant's arguments were
misconceived and explained that its declaration of invalidity did
not delete marihuana as a controlled substance in Schedule II.
The Court of Appeal was correct in reaching this conclusion. As
the Court aptly noted, pursuant to s.52(l) of the Constitution
Act, the court only had jurisdiction to declare the prohibition
against marihuana unconstitutional to the extent of its
inconsistency with the Constitution. Since the constitutional
issue in Parker was restricted to possession of marihuana for
medical purposes, and not for the purposes of trafficking, the
declaration of invalidity was restricted to the prohibition
against marihuana only in relation to the offence of simple
possession under the CDSA. All other offence provisions in
respect of marihuana, such as production of marihuana,
trafficking in marihuana, possession of marihuana for the purpose
of trafficking, and importing of marihuana, remained in full
force and effect.

23. Since there was no declaration of invalidity in respect of
the offence of possession for the purpose of trafficking, that
offence existed at the time the Applicant was alleged to have
committed the crime.

24. Finally, the Applicant has failed to explain the significant
delay in bringing this application for leave to appeal. Although
the Applicant is a self-represented litigant, he is not
inexperienced in litigation matters. In addition to the various
proceedings advanced by the Applicant in the courts below as a
self-represented litigant, the Applicant has acted on his own
behalf in numerous other proceedings in the past: see
R. v. Turmel, [1996] O.J. No. 2835 (Ont. C..A.);
R. v. Turmel, [1995] O.J. No. 2683 (Ont. C.A.);
R. v. Turmel, [1995] O.J. No. 4308 (Ont. Ct. Prov. Div.);
R. v. Turmel, [1995] O.J. No. 1302 (Ont. Ct. Prov. Div.);
R. v. Turmel, [1995] O.J. No. 629 (Ont. C.A.);
R. v. Turmel, [1994] O.J. No. 2406 (Ont. Ct. Prov. Div.);
Turmel v. CBC, [1990] O.J. No. 1640 (Ont. H.C.);
R. v. Turmel, [1984] O.J. No. 1989 (Ont. C.A.).

B. THE APPLICANT HAD NO RIGHT OF APPEAL TO THE COURT OF APPEAL
FOR ONTARIO

25. In addition, the Applicant did not have a right of appeal to
the Court of Appeal.

26. It is settled law that there are no interlocutory appeals in
criminal matters. All criminal appeals are statutory.22 Pursuant
to s. 674 of the Criminal Code, "No proceedings other than those
authorized by this Part and Part XXVI shall be taken by way of
appeal in proceedings in respect of indictable offences".23

27. As La Forest, J. stated in Kourtessis v. M.N.R.:

"Appeals are solely creatures of statute: see R. v.
Meltzer (1989), 49 C.C.C. (3d) 453 at p. 460, [1989] 1
S.C.R. 1764, 70 C.R. (3d) 383. There is no inherent
jurisdiction in any appeal court. Nowadays, however,
this basic proposition tends at times to be forgotten.
Appeals to appellate courts and to the Supreme Court of
Canada have become so established and routine that
there is a widespread expectation that there must be
some way to appeal the decision of a court of first
instance. But it remains true that there is no right of
appeal on any matter unless provided for by the
relevant legislature.
There are various policy reasons for enacting a
procedure that limits rights of appeal. Sometimes the
opportunity for more opinions does not serve the ends
of justice. A trial court, for example, is in a better
position to assess the factual record. Thus, most
criminal appeals are restricted to questions of law or
mixed questions of law and fact.

A further policy rationale, and one that is important
to the case before this court, is that there should not
be unnecessary delay in the final disposition of
proceedings, particularly proceedings of a criminal
character. This is especially applicable to
interlocutory matters which can ultimately be decided
at trial: see R. v. Mills (1986), 26 C.C.C. (3d) 481,
29 D.L.R. (4th) 161, [1986] 1 S.C.R. 863. On this
point, McLachlin J., speaking for the majority in R. v.
Seaboyer (1991), 66 C.C.C. (3d) 321 at p. 414, 83
D.L.R. (4th) 193, [1991] 2 S.C.R. 577, noted that there
was a valid policy concern to control the "plethora of
interlocutory appeals and the delays which inevitably
flow from them". Such review should, in the court's
view, normally take place at trial."24 [emphasis added]

28. Pursuant to s. 553 (c) (xi) of the Criminal Code, the offence
in respect of which the Applicant was charged fell within the
absolute jurisdiction of a provincial court judge.23

29. Pursuant to section 601 of the Criminal Code, the court
having jurisdiction over the proceedings has the exclusive
jurisdiction to determine the validity of an information or an
indictment. The Applicant's motion to quash the information
charging him with the offence of possession of cannabis
(marihuana) for the purpose of trafficking was brought in the
Superior Court rather than the Ontario Court of Justice. The
Applicant' motion to quash the information was thus brought in
the wrong forum, and Aitken, J. had no jurisdiction to grant the
Applicant the relief he sought.25

PART IV - SUBMISSIONS ON COSTS
The Respondent makes no submissions as to costs in respect of
this matter.

PART V - ORDER SOUGHT

31. The Respondent respectfully requests that the within
application for leave to appeal be dismissed.

ALL OF WHICH IS RESPECTFULLY SUBMITTED
Dated at Toronto this 4th day of November, 2004.
Croft Michaelson
Vanita Goela

ATTORNEY GENERAL OF CANADA
Department of Justice
130 King Street West Suite 3400, Box 36
Toronto, Ontario M5X 1K6
Per: Croft Michaelson/ Christopher Leafloor
Vanita Goela Tel: (416) 952-7261/ (416) 973-0392/ (416) 9"
9638 Fax: (416)973-3004
E-mail: croft.michaelson@justice.gc.ca
Of Counsel for the Respondent

Notes:
1- Controlled Drugs and Substances Act, S.C. 1996, c. 19. 2-
Applicant's Notice of Appeal, dated June 9, 2003.
3- Hitzig v. Canada (2003), 231 D.L.R. (4th) 190 (Ont. C.A.) [R.
v. Turmel].
4- Applicant's Notice of Application for Leave to Appeal,
Application for Leave to Appeal, pp.1-3.
5- Applicant's Memorandum of Argument, Application for Leave to
Appeal, pp. 9-13, para. 3.
6- Applicant's Notice of Application for Leave to Appeal,
Application for Leave to Appeal, pp.1-3.
7- R. v. Parker (2000), 49 O.R. (3d) 481 (C.A.) [Parker].
8- Parker, supra at para. 1.
9- Marihuana Medical Access Regulations, SOR/DORS 2001-227.
10- Hitzig (Ont. C.A.), supra, note 3 at paras. 1 and 39. This
Honourable Court denied a number of the appellants in Hitzig
leave to appeal: Hitzig v. Canada, [2004] S.C.C.A. No. 5 (QL).
11- Criminal Code of Canada, R.S.C. 1985, c. C-46, s. 553.
12- Notice of Motion, dated May 20 2003, returnable May 26 2003.
13- Parker, supra note 7.
14- Affidavit of John C. Turmel, dated May 20, 2003.
15- Endorsement of Aitken, J., dated May 26, 2003, Application
for Leave to Appeal, pp. 5.
16-Applicant's Notice of Appeal, dated June 9, 2003.
17- Hitzig, supra note 3 (R. v. Turmel).
18- Applicant's Memorandum of Law, Application for Leave to
Appeal, pp. 9-13 at para. 3.
19- Applicant's Memorandum of Law, Application for Leave to
Appeal, pp. 9-13 at paras. 1 and 4.
20- Parker, supra note 7 at para. 210.
21- See also: R. v. Krieger (2000), 225 D.L.R. (4th) 164 (Alta.
Q.B). aff d (2002), 225 D.L.R. (4th) 183 (Alta C.A.); leave to
appeal to this Honourable Court denied, [2003] S.C.C.A. No.114.
In this case the court upheld the constitutional validity of the
offence of possession of cannabis marihuana for the purpose of
trafficking. (The Alberta Court of Appeal ordered a new trial on
the trafficking charge, but only with respect to the trial
judge's charge to the jury regarding the defence of necessity.
The validity of the trafficking offence was not overturned.)
22- R. v. Meltzer, [1989] 1 S.C.R. 1764.
23- Criminal Code of Canada, R.S.C. 1985, c. C-46, s. 674.
24- Kourtessis v. M.N.R., [1993] 2 S.C.R. 53 at 294-95; R. v.
Multitech Warehouse Direct (Ontario) Inc. (1989), 52 C.C.C. (3d)
175 (Ont. C.A.).
25- Criminal Code of Canada, R.S.C. 1985, c. C-46, ss. 601(1),
601(10).
 
PART VI - TABLE OF AUTHORITIES PARAGRAPH NUMBER
Hitzig v. Canada (2003), 231 D.L.R. (4th) 190 (Ont. C.A.) 3, 8,14
Hitzig v. Canada, [2004] S.C.C.A. No. 5 8
Kourtessis v. M.N.R.., [1993] 2 S.C.R. 53 27
R. v. Krieger (2000), 225 D.L.R. (4th) f4 (Alba. Q.B), affmd
(2002), 225 D.L.R. (4th) 183 (Alba C.A.); Application for Leave
to Appeal denied [2003] S.C.C.A. No. 114. 21
R. v. Meltzer [1989], 1 S. C.R. 1764 26
R. v. Multitech Warehouse Direct (Ontario) Inc. (1989), 52 27
C.C.C. (3d) 175 (Ont. C.A.)
R. v. Parker (2000), 49 O.R. (3d) 481 (C.A.) 4, 7,11, 21
R. v. Seaboyer, [1991] 2 S.C.R. 577
                       

PART VII - STATUTES, REGULATIONS, RULES RELIED ON
1. Controlled Drugs and Substances Act, S.C. 1996, c. 19, s.4,
5(2)
2. Criminal Code of Canada, R.S.C. 1985, c. C-46, ss. 601(1),
601(10), 553 ; 647
3. Marihuana Medical Access Regulations, SOR/2001 -227
4. Marihuana Exemption (Food and Drugs Act) Regulations,
SOR/2003-261
5. Regulations Amending the Marihuana Medical Access Regulations,
SOR/20 387

PART I
OFFENCES AND PUNISHMENT
Particular Offences 4(1) Possession of substance
4. (1) Except as authorized under the regulations, no person
shall possess a substance included in Schedule I, II or III.
4(2) Obtaining substance
(2) No person shall seek or obtain
(a) a substance included in Schedule I, II, III or IV, or
(b) an authorization to obtain a substance included in Schedule
I, II, III or IV
from a practitioner, unless the person discloses to the
practitioner particulars relating the acquisition by the person
of every substance in those Schedules, and of every authorization
to obtain such substances, from any other practitioner within the
preceding thirty days.
4(3) Punishment
(3) Every person who contravenes subsection (I) where the
subject-matter of the offence is a substance included in Schedule
I
(a) is guilty of an indictable offence and liable to imprisonment
for a term not exceeding seven years; or
(b) is guilty of an offence punishable on summary conviction and
liable
(i) for a first offence, to a fine not exceeding one thousand
dollars or to imprisonment for> a term not exceeding six months,
or to both, and
(ii) for a subsequent offence, to a fine not exceeding two
thousand dollars or to imprisonment for a term not exceeding one
year, or to both.
4(4) Punishment
(4) Subject to subsection (5), every person who contravenes
subsection (1) where the subject-matter of the offence is a
substance included in Schedule II
(a) is guilty of an indictable offence and liable to imprisonment
for a term not exceeding five years less a day; or
(b) is guilty of an offence punishable on summary conviction and
liable
(i) for a first offence, to a fine not exceeding one thousand
dollars or to imprisonment /r a term not exceeding six months, or
to both, and
(ii) for a subsequent offence, to a fine not exceeding two
thousand dollars or to imprisonment for a term not exceeding one
year, or to both.
4(5) Punishment
(5) Every person who contravenes subsection (1) where the
subject-matter of the offence is a substance included in Schedule
II in an amount that does not exceed the amount scr out for that
substance in Schedule VIII is guilty of an offence punishable on
summary conviction and liable to a fine not exceeding one
thousand dollars or to imprisonment f< a term not exceeding six
months, or to both.
4(6) Punishment
(6) Every person who contravenes subsection (1) where the
subject-matter of the offend is a substance included in Schedule
III
(a) is guilty of an indictable offence and liable to imprisonment
for a term not exceeding three years; or
(b) is guilty of an offence punishable on summary conviction and
liable
(i) for a first offence, to a fine not exceeding one thousand
dollars or to imprisonment to a term not exceeding six months, or
to both, and
(ii)for a subsequent offence, to a fine not exceeding two
thousand dollars or to imprisonment for a term not exceeding one
year, or to both.
4(7) Punishment
(7) Every person who contravenes subsection (2)
(a) is guilty of an indictable offence and liable
(i) to imprisonment for a term not exceeding seven years, where
the subject-matter of the. offence is a substance included in
Schedule I,
(ii) to imprisonment for a term not exceeding five years less a
day, where the subject-matter of the offence is a substance
included in Schedule 11,
(Hi) to imprisonment for a term not exceeding three years, where
the subject-matter of: offence is a substance included in
Schedule III, or
(iv) to imprisonment for a term not exceeding eighteen months,
where the subject-matter of the offence is a substance included
in Schedule IV; or
(b) is guilty of an offence punishable on summary conviction and
liable
(i) for a first offence, to a fine not exceeding one thousand
dollars or to imprisonment r a term not exceeding six months, or
to both, and
(ii) for a subsequent offence, to a fine not exceeding two
thousand dollars or to imprisonment for a term not exceeding one
year, or to both.
4(8) Determination of amount
(8) For the purposes of subsection (5) and Schedule VIII, the
amount of the substance means the entire amount of any mixture or
substance, or the whole of any plant, that contains a detectable
amount of the substance.
Trafficking in substance
5. (1) No person shall traffic in a substance included in
Schedule I, II, HI or IV or in ar. substance represented or held
out by that person to be such a substance.
5(2) Possession for purpose of trafficking
(2) No person shall, for the purpose of trafficking, possess a
substance included in Schedule I, II, III or IV.
5(3) Punishment
(3) Every person who contravenes subsection (I) or (2)
(a) subject to subsection (4), where the subject-matter of the
offence is a substance included in Schedule I or II, is guilty of
an indictable offence and liable to imprisonment for life;
(b) where the subject-matter of the offence is a substance
included in Schedule III,
(i) is guilty of an indictable offence and liable to imprisonment
for a term not exceeding ten years, or
(ii) is guilty of an offence punishable on summary conviction and
liable to imprisonment for a term not exceeding eighteen months;
and
(c) where the subject-matter of the offence is a substance
included in Schedule IV,
(i) is guilty of an indictable offence and liable to imprisonment
for a term not exceeding three years, or
(ii) is guilty of an offence punishable on summary conviction and
liable to imprisonment for a term not exceeding one year.
5(4) Punishment in respect of specified substance
(4) Every person who contravenes subsection (I) or (2), where the
subject-matter of the offence is a substance included in Schedule
II in an amount that does not exceed the amount set out for that
substance in Schedule VII, is guilty of an indictable offence and
liable to imprisonment for a term not exceeding five years less a
day.
5(5) Interpretation
(5) For the purposes of applying subsection (3) or (4) in respect
of an offence under subsection (1), a reference to a substance
included in Schedule I, II, III or IV includes <.< reference to
any substance represented or held out to be a substance included
in that Schedule.
5(6) Interpretation
(6) For the purposes of subsection (4) and Schedule VII, the
amount of the substance means the entire amount of any mixture or
substance, or the whole of any plant, that contains a detectable
amount of the substance.

--
Abolitionist Slave Leader John C."The Banking Systems Engineer" Turmel
for UNILETS interest-free time-based currency in U.N. resolution C6
to Governments in the http://www.un.org/millennium/declaration.htm 
http://www.cyberclass.net/turmel 519-753-0645 USENET: can.politics

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